This summary also appears under Administrative Law
Issues: Whether a worker's compensation hearing must be held at the location where the alleged injury occurred; MCL 418.851; Mandamus relief; In re MCI Telecomm. Complaint; "Locality" defined; Deference to agency interpretations; In re Complaint of Rovas Against SBC MI; Worker's Disability Compensation Act (WDCA)(MCL 418.101 et seq.); Convenience of the hearing; Crane v. Leonard, Crossette & Riley
Court: Michigan Supreme Court
Case Name: Younkin v. Zimmer
e-Journal Number: 58595
Judge(s): Young, Jr., Cavanagh, Markman, Kelly, Zahra, McCormack, and Viviano
In a memorandum opinion, the court held that the trial court abused its discretion by issuing a writ of mandamus compelling the defendants-worker's compensation administrators to ensure that worker's compensation hearings are held in the county in which the alleged injury occurred. Thus, it reversed the judgment of the Court of Appeals, which had affirmed the trial court, and remanded to the trial court for the entry of an order denying relief on the plaintiff's complaint for mandamus. Plaintiff sought worker's compensation benefits for an injury he suffered while working in Genesee County. Defendants then advised him that the Genesee County hearing site would be closed and his case would be transferred to the Dimondale site in Eaton County, approximately 70 miles away. In response, he filed his mandamus action to compel defendants to maintain the Genesee County hearing site. The trial court granted mandamus relief, and the Court of Appeals affirmed. The court rejected the lower courts' rulings. "To the extent that the Court of Appeals held that because the injury occurred in Genesee County the hearing must also be held in Genesee County, we note that if this were required, there would have to be a hearing site in every county of our state, and there obviously is not." Further, nothing within the WDCA "requires that there be a hearing site in every county." Rather, the statute "simply requires the hearing to be held 'at the locality where the injury occurred.'" The court thus found that it was not "unreasonable to conclude that the 'locality where the injury occurred' in this case was Dimondale when the injury occurred in Genesee County and that county falls within the Dimondale district. Although having the hearing in the latter rather than in the former venue will doubtlessly be less convenient for plaintiff, we do not believe that this constitutes an unreasonable inconvenience." The court concluded that plaintiff did not have "a clear legal right to a hearing in Genesee County and defendants do not have a clear legal obligation to hold the hearing in Genesee County."
© 2014 State Bar of Michigan